EFTA00206072¶
-----Original Message-----¶
From: Paul Cassell¶
Sent: Thursday, December 01, 2011 11:25 AM¶
Cc: ‘Brad Edwards’¶
Subject: RE: Discovery Issues in Epstein¶
Dear Mr.¶
We will shortly be filing a motion to compel Government responses to our discovery requests — discovery which, as you know, Judge Marra has already ordered. We realize, of course, that the Government has filed a motion to dismiss/stay. But if the Government’s position is rejected on those motions, then the next issue is what discovery can we expect to receive from the Government.¶
If the motions are denied, will the Government voluntarily produce anything to us? Will the government at least agree to produce the following:¶
(1) The Government’s initial disclosures pursuant to Fed. R. Civ. P. 26;¶
(2) Answers to all of the victims’ requests for admission;¶
(3) All documents, correspondence, and other information that the Government distributed to persons or entities outside of the federal Government or received from persons or entities outside of the federal government; and¶
(4) All documents, correspondence, and other information covered by the victims’ discovery request that is not subject to a claim of privilege.¶
And, for all other information withheld, will the Government agree to produce a document-by-document privilege log, as required by the local rules?¶
Thanks for your help on these questions and Brad and I have.¶
Sincerely,¶
Paul Cassell¶
Co-Counsel for Jane Doe #1 and Jane Doe #2¶
Paul G. Cassell¶
EFTA00206073¶
Ronald N. Boyce Presidential Professor of Criminal Law S.J. Quinney College of Law at the University of Utah¶
332 South 1400 East, Room 101¶
Salt Lake City, UT 84112-0730¶
http://www.law.utah.edu/profiles/default.asp?PersonID=57&name=Cassell,Paul¶
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Sunday, December 04, 2011 2:00 PM¶
Subject:¶
RE: extra pages¶
No objection to the extra pages. I hope that all went well on Friday.¶
A. Villafaña¶
Assistant U.S. Attorney¶
-----Original Message-----¶
From: Paul Cassell [mailto:cassellp@law.utah.edu]¶
Sent: Sunday, December 04, 2011 1:55 PM¶
To: [blank], [blank] (USAFLS); [blank], [blank]. (USAFLS)¶
Cc: Brad Edwards¶
Subject: RE: extra pages¶
Sorry I had to leave the call early Friday. Meant to check with you on this then.¶
I am working with Brad to finalize our pleadings to be filed on Monday in response to the motion to dismiss. We are filing an unsealed pleading (that does not discuss grand jury material) as well as a sealed pleading (that discusses only the grand jury material and related issues). The unseal pleading is 24 pages long and the sealed pleading is 7 pages long.¶
We also have a response to the motion to stay which is well under the 20 page limit.¶
Any objection to a motion for the extra pages (4+7, although I’m not sure whether we count the 7) to respond to your motion to dismiss?¶
Thanks for your help on getting back to us. PC Paul G. Cassell¶